PRASA/CAPR HAS NOT COMPLIED WITH THE PROVISIONS OF THE ADMINISTRATIVE ORDER CWA-02-2001-3020 ISSUED ON NOVEMBER 20, 2000 WHICH REQUIRED PRASA/CAPR TO IMMEDIATELY CEASE THE DISCHARGES OF POLLUTANTS TO THE WATERS OF THE UNITED STATES. PARTICULARLY, PRASA/CAPR HAS NOT COMPLIED WITH THE PROVISION OF SUBMITTING A REPORT TO EPA THAT DESCRIBES THE ACTIONS THAT PRASA/CAPR HAS TAKEN OR WILL TAKE TO CORRECT THE AFOREMENTIONED DEFICIENCIES AND PROVIDE A DETAILED SCHEDULE TO COMPLET THE REQUIRED REPAIRS. ON JULY 13, 2001, EPA REGION 2 ISSUED A PENALTY COMPLAINT AGAINST PRASA/CAPR FOR VIOLATIONS TO THE CLEAN WATER ACT FROM SEPTEMBER 12, 2000 THROUGH MARCH 31, 2001 FOR A TOTAL OF 197 DAYS OF VIOLATIONS; AND THE COMPLAINT PROPOSED A PENALTY OF $137,500.00. THE PROPOSED CA/FO INCLUDES A CASH SETTLEMENT OF $95,000.00 TO BE PAID ON OR BEFORE 45 CALENDAR DAYS AFTER THE DATE OF SIGNATURE OF THE FINAL ORDER.